Privacy Policy

This Privacy Policy is issued by PropCompass Pty Ltd (ABN 19 691 507 856), the holder of real estate licence 10152933 (NSW) and equivalent corporate licences in Queensland and Victoria (we, us, our). Our registered address is 95B Station Street, Penrith NSW 2750.

Scope of This Policy

This document serves as both our Privacy Policy and our Collection Notice under APP 5. It covers personal information we collect through our website at propcompass.com.au and through our buyer's advocacy, property investment advisory, and related services. By using our website or engaging our services, you acknowledge this policy.

Anonymity and Pseudonyms

You may browse our website and submit general enquiries without identifying yourself or by using a pseudonym, where it is practicable to do so. However, we are required to collect and verify your full identity when you:

• Engage us to provide buyer's advocacy or advisory services under a formal agreement.
• Execute a contract for the purchase of property.
• Undergo customer due diligence under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth) (AML/CTF Act).
• Are required to be identified under any other applicable law.

We cannot act as your buyer's agent, lodge offers, or execute contracts on your behalf without verified identification.

Information We Collect

We collect personal information from you when you:

• Complete an enquiry form or contact us through our website.
• Book an appointment, consultation, or call.
• Engage us to provide property advocacy, investment advisory, or related services.
• Subscribe to our newsletter, blog, or updates.
• Communicate with us by phone, email, or social media.
• Attend property inspections, auctions, or open homes as our client.

The types of personal information we may collect include:

• Name, email address, phone number, and postal address.
• Property preferences, budget, and purchase requirements.
• Financial information relevant to our services (for example, borrowing capacity, pre-approval status, investment goals).
• Identification documents (for example, driver's licence, passport) where required for contract execution or AML/CTF compliance.
• Information about your legal or entity structure (for example, SMSF trustee details, company details, joint purchase arrangements).
• Any other information you voluntarily provide to us.

We may also collect non-identifiable information such as browser type and website usage statistics via analytics tools (see the Cookies and Website Analytics section below).

Legal Basis for Collection

In some circumstances we are required or authorised by law to collect personal information, including under:

• The AML/CTF Act 2006 (Cth) and AML/CTF Rules (customer due diligence, ongoing monitoring, and reporting obligations).
• The Property and Stock Agents Act 2002 (NSW) and equivalent state legislation in Queensland and Victoria (agency agreement, trust account, and record-keeping obligations).
• Taxation legislation administered by the Australian Taxation Office.
• Any court order or requirement of a government agency.

Consequences of Not Providing Information

If you do not provide the personal information we request, we may be unable to:

• Enter into or perform a buyer's agency agreement with you.
• Lodge offers, bid at auction, or execute contracts on your behalf.
• Fulfil our obligations under the AML/CTF Act (which may prevent us from accepting your engagement).
• Provide you with tailored property research or investment recommendations.

Sensitive Information

Sensitive information (including health information, ethnic origin, and similar categories defined in the Privacy Act) is subject to a higher standard of protection under APP 3. We collect sensitive information only where it is reasonably necessary for the services you have requested and only with your consent, except where required or authorised by law.

In a property context, sensitive information may arise where you provide information about accessibility requirements, age-care circumstances, or financial hardship. If you share such information, we will use it only for the purpose for which it was provided. We will seek your express consent at the time of collection for any sensitive information material to your engagement.

Government Identifiers

We may collect government-related identifiers such as driver's licence numbers and passport numbers for the purpose of contract execution, cooling-off management, and AML/CTF customer due diligence. For SMSF purchases, tax file numbers may also be involved.

We collect these identifiers only where required for these specific transactional and legal purposes. We do not adopt government identifiers as our own internal client references. Tax file numbers are handled in accordance with the Privacy (Tax File Number) Rule 2015.

How We Use Your Information

We use the personal information we collect to:

• Provide and manage our buyer's advocacy, investment advisory, and related services.
• Respond to your enquiries and communicate with you effectively.
• Conduct property research and deliver tailored recommendations.
• Carry out customer due diligence and other obligations under the AML/CTF Act.
• Maintain records as required under real estate licensing legislation.
• Improve our website, services, and client experience.
• Send you relevant updates, property insights, market news, and marketing communications (you can opt out at any time - see Direct Marketing below).
• Comply with legal obligations and resolve disputes.

How We Store and Protect Your Information

We take reasonable steps to protect personal information from misuse, interference, loss, unauthorised access, modification, and disclosure. Our safeguards include organisational, physical, and technical controls appropriate to the sensitivity of the information held. We review our security measures regularly.

Where we use third-party service providers (such as email systems, CRM platforms, scheduling tools, or analytics tools) to store or process personal information, we take steps to ensure those providers maintain appropriate security standards.

Data Retention and Destruction

We retain personal information only for as long as reasonably necessary for the purposes for which it was collected, or as required by law. Key minimum retention periods that apply to our business include:

• AML/CTF records: seven years after the end of the customer relationship, as required by the AML/CTF Act 2006 (Cth).
• Real estate transaction and agency agreement records: five years, as required by the Property and Stock Agents Act 2002 (NSW) and equivalent state legislation.
• Tax records: five years from the date the record was prepared, as required by the Income Tax Assessment Act 1997 (Cth).

When personal information is no longer needed and no legal retention obligation applies, we take reasonable steps to destroy it securely or to de-identify it.

Disclosure of Information

PropCompass will not sell, rent, or trade your personal information. We may disclose personal information where necessary to:

• Facilitate property transactions (for example, to vendors' agents, conveyancers, solicitors, mortgage brokers, lenders, valuers, and building and pest inspectors).
• Provide services through trusted third-party partners (for example, CRM and communication platforms, cloud storage providers, scheduling tools, and analytics services).
• Comply with our obligations under the AML/CTF Act 2006 (Cth), including disclosures to AUSTRAC, law enforcement agencies, or financial institutions.
• Comply with any other legal requirement, court order, or government request.
• NSW Fair Trading, the Office of Fair Trading Queensland, Consumer Affairs Victoria, or other regulatory bodies in connection with licensing obligations.

All third parties we work with are required to handle your information consistently with this Privacy Policy and applicable privacy law.

Overseas Disclosure

Some of the third-party service providers we use store or process personal information on servers located overseas. Countries where data may be held or processed include the United States of America and Ireland (common locations for major cloud, CRM, and analytics platforms). Other countries may be added as our technology stack changes, and this policy will be updated accordingly.

We are required under APP 8 to take reasonable steps to ensure that overseas recipients handle personal information in a manner consistent with the Australian Privacy Principles. However, you should be aware that some overseas jurisdictions may not have privacy laws that provide protections substantially similar to those under the Privacy Act 1988 (Cth). Where this is the case, we use contractual safeguards (such as Data Processing Agreements or standard contractual clauses) to require appropriate handling.

By engaging our services or using our website, you acknowledge that your personal information may be transferred to, held in, or accessed from overseas.

Cookies and Website Analytics

Our website uses cookies and third-party analytics and advertising tools which may include:

• Google Analytics (website usage analysis and performance measurement).
• Meta Pixel and similar advertising tools (campaign measurement and retargeting).
• LinkedIn Insight Tag and similar tools (professional audience measurement).
• Other third-party tracking or session tools we may deploy from time to time.

These tools may collect IP addresses, device identifiers, and browsing behaviour that can, individually or in combination, constitute personal information under the Privacy Act. This information is used for website analytics, advertising measurement, and retargeting purposes.

You can limit cookie collection by adjusting your browser settings to block or delete cookies. You may also use the opt-out tools provided by individual platforms (such as Google Analytics Opt-out, Meta Ad Preferences, and LinkedIn Ads Settings). Note that disabling cookies may affect website functionality.

Direct Marketing

We may contact you with updates about property insights, market news, or our services by email, SMS, telephone, or targeted social media advertising. We do so only where you have consented or where permitted under the Spam Act 2003 (Cth) and the Do Not Call Register Act 2006 (Cth).

All commercial electronic messages (email and SMS) will include clear identification of PropCompass as the sender and a functional unsubscribe facility. We comply with the Spam Act 2003 and will not send commercial messages to numbers registered on the Do Not Call Register without your consent.

To opt out of any or all marketing communications, you may:

• Click the unsubscribe link in any email we send you.
• Reply STOP to any SMS we send you.
• Email The Privacy Officer at privacy@propcompass.com.au to opt out of all marketing channels.

We will process opt-out requests within a reasonable time. Note that opting out of marketing does not affect service communications necessary for active engagements.

Access and Correction

You may request access to, or correction of, the personal information we hold about you at any time by contacting The Privacy Officer using the details in the Complaints and Contact section below. We will respond within 30 days of receiving your request.

We may charge a reasonable fee to cover the cost of retrieving and providing access to your information. No fee is charged for requesting a correction. If we refuse access or correction, we will provide written reasons, refer you to the complaints mechanism in this policy, and note any other prescribed information. Grounds for refusal may include circumstances where providing access would unreasonably impact the privacy of others, where the information relates to anticipated legal proceedings, or other grounds set out in APP 12.

Notifiable Data Breaches

We maintain a documented data breach response plan consistent with the Notifiable Data Breach (NDB) Scheme under Part IIIC of the Privacy Act. If we become aware of a suspected data breach we will:

• Assess whether the breach is an eligible data breach likely to result in serious harm, within 30 days as required by the NDB Scheme.
• Notify the OAIC and affected individuals as soon as practicable if the breach is eligible.
• Take remedial steps to contain the breach and reduce the risk of recurrence.

Anti-Money Laundering and Counter-Terrorism Financing

From 1 July 2026, real estate agents become Tranche 2 reporting entities under the AML/CTF Act 2006 (Cth) as amended by the Anti-Money Laundering and Counter-Terrorism Financing Amendment Act 2024 (Cth). PropCompass will be a reporting entity under that Act.

In connection with our AML/CTF obligations, we may collect and handle personal information including:

• Identity documents (driver's licence, passport, and similar) for customer due diligence (CDD).
• Information about source of funds, source of wealth, and beneficial ownership.
• Ongoing transaction monitoring information.

This information may be disclosed to AUSTRAC, law enforcement agencies, or financial institutions in connection with our obligations under the AML/CTF Act. AML/CTF records are retained for seven years after the end of the customer relationship. The small business exemption under s 6D of the Privacy Act does not apply to our AML/CTF-related activities.

Automated Decision-Making

From 10 December 2026, new obligations under APPs 1.7 to 1.9 (inserted by the Privacy and Other Legislation Amendment Act 2024 (Cth)) will require disclosure where a computer program is used to make, or substantially assist in making, decisions that could reasonably be expected to significantly affect individuals' rights or interests.

We are currently auditing our use of analytical tools, property research platforms, and CRM systems to identify any decision-making processes that will fall within scope. This section will be updated with full APP 1.7 to 1.9 disclosures before 10 December 2026. We do not use fully automated decision-making that produces binding decisions affecting individuals without human review.

Complaints

If you have a complaint about how we have handled your personal information or a potential breach of the Australian Privacy Principles, please contact The Privacy Officer in the first instance:

We will acknowledge your complaint within 7 business days and aim to provide a substantive response within 30 days. If we require additional time we will notify you of the reason and the expected resolution date.

If you are not satisfied with our response, or if you do not hear from us within 30 days, you may escalate your complaint to:

• Office of the Australian Information Commissioner (OAIC)
  Phone: 1300 363 992
  Online: www.oaic.gov.au/privacy/privacy-complaints
  Post: GPO Box 5218, Sydney NSW 2001
• NSW Fair Trading (for conduct-related complaints about our real estate licence)
  Phone: 13 32 20
  Online: www.fairtrading.nsw.gov.au
• Office of Fair Trading Queensland (for Queensland-licensed activities)
  Phone: 13 74 68
• Consumer Affairs Victoria (for Victoria-licensed activities)
  Phone: 1300 55 81 81

Contact Us

For all privacy-related enquiries, access and correction requests, opt-out requests, or complaints, please contact The Privacy Officer:

For general service enquiries (not privacy matters), please contact us at info@propcompass.com.au.

Updates to This Policy

We may update this Privacy Policy from time to time to reflect changes in our business practices, legal obligations, or regulatory guidance. The current version is always available at propcompass.com.au/privacy. For material changes we will notify active clients by email.

Acceptance of This Privacy Policy

By using our website or engaging our services, you acknowledge that you have read this Privacy Policy and authorise the collection, use, disclosure, and handling of your personal information as described in it.

This policy is provided for information purposes and does not constitute legal advice. Given the imminent AML/CTF Tranche 2 commencement on 1 July 2026 and the automated decision-making obligations commencing 10 December 2026, this policy will be reviewed by Australian privacy counsel before those dates.